As a member of the National Security/CFIUS/Compliance Practice Group, Mr. Brewster represents foreign and domestic clients in acquisitions that affect U.S. national security; helps foreign-owned clients acquire and maintain security clearances; and advises on compliance with U.S. trade sanctions and embargoes, U.S. export control laws, the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws.
He has represented clients in suspension and debarment proceedings before the Department of Defense, the Air Force, the Army, the U.S. Department of State, and the Environmental Protection Agency, and in export compliance matters before the U.S. Department of State, the U.S. Department of Commerce and the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC), including licensing proceedings, voluntary disclosures and the defense of government investigations and enforcement actions. His FCPA experience includes an internal investigation involving the United Nations Oil for Food program, defense of an SEC investigation involving bribery allegations in Eastern Europe, and the development of numerous corporate compliance policies and anti-bribery training programs.
Mr. Brewster directs Stroock’s legislative practice, offering analysis as well as advocacy on matters before Congress and regulatory agencies.
He has advised clients on numerous legislative and regulatory matters, including representation before Congress on labor and employment, antitrust, tax, federal contracting and telecommunications legislation, and in drafting comments in federal regulatory proceedings. He has supported the defense of a Congressional investigation, developed federal and national lobbying campaigns, and advised on compliance with federal election, lobbying and ethics laws. A former radio and television broadcaster, he has also helped structure media campaigns and communications strategies.
Mr. Brewster also counsels and represents clients on consumer product safety, advertising and other consumer protection matters before state and federal agencies, including the FTC and the U.S. Consumer Product Safety Commission (CPSC). He counsels clients on compliance with the Consumer Product Safety Act, the Consumer Product Safety Improvements Act and related statutes and regulations. He has counseled clients in product recalls and in a civil penalty proceeding before the CPSC, and has developed compliance programs, crisis management policies and public service campaigns.
He also advises clients on advertising and marketing issues, including false advertising, warranties, testimonials, and new media campaigns, and has represented clients in enforcement matters and rulemakings before state attorneys general and the FTC. He has also helped develop numerous national and regional sweepstakes, contests and promotions.
Before joining Stroock, Mr. Brewster was counsel in a major international law firm. Before private practice, he was Associate Director for Marketing Practices in the FTC’s Bureau of Consumer Protection, with principal responsibility for prosecution of consumer fraud warranties and defective products, among other matters.
Prior to joining the FTC, Mr. Brewster was a legislative assistant and committee counsel for U.S. Senator John C. Danforth (R-MO) and counsel to the U.S. Senate Committee on Governmental Affairs (now the Committee on Homeland Security and Governmental Affairs). He helped draft numerous federal laws, including the Ethics in Government Act and the Paperwork Reduction Act, which created the White House Office of Information and Regulatory Affairs.
Mr. Brewster also served as a state assistant attorney general in Missouri, where he prosecuted consumer fraud cases and criminal appeals, and represented the state labor board.
- Over 100 Exon-Florio reviews before CFIUS on acquisitions ranging in value from less than $1 million to $38 billion, including: representation of a German multi-national before CFIUS and the Directorate of Defense Trade Controls in connection with a $5 billion acquisition by a Chinese corporation, the largest acquisition ever of a German company by a Chinese buyer; acquisitions by one of the principal industrial groups operating worldwide in the aerospace, defense and security sectors, by the world’s largest supplier of commercial airplane assemblies and components; negotiation and implementation of CFIUS National Security Agreements to resolve investigations and clear transactions.
- FCPA investigations, training and compliance programs.
- Mitigation of Foreign Ownership Control or Influence (FOCI) for foreign-owned, cleared U.S. government contractors. Obtained only Secretarial waivers ever granted of statutory prohibition against contracting with foreign government-controlled corporations on highly classified defense projects, drafted and helped secure amendments to federal law allowing similar waivers for environmental remediation contracts.
- Export-control matters before the U.S. Departments of State and Commerce.
- Trade sanctions matters before the U.S. Department of the Treasury, OFAC and OFAC Compliance Programs.
- Successful resolution of debarment and suspension actions in negotiated agreements, allowing contractors to return to work on government projects.
- Defense of enforcement actions by FTC and CPSC.
- Advice and counsel on product recalls of toys, consumer electronics, furniture, clothing, construction materials and electrical components.
- Speaker, “CFIUS in a Time of Change: How Investors and Counsel Must Adapt to a Changing Environment for Foreign Investment Reviews,” PLI Webcast, June 14, 2018
- Speaker, "The Annual Aerospace & Defense Acquisitions Roundtable," Washington, DC, April 19, 2016
- Speaker, "CFIUS Annual Report: 147 Reviews. 24 Chinese.," PLI Webinar, April 7, 2016
- Speaker, Special Briefing for Embassy of the United Kingdom, Washington, DC, February 26, 2016
- Speaker, U.S. Legal Implications of Foreign Direct Investment, Briefing for Chinese CEO's, Washington, DC, September 23, 2015
- Speaker, CFIUS's Web: From Pig Farms to the Waldorf - How Real Estate and Other Transactions Outside the Defense Sector May Trigger CFIUS Review, PLI Webcast, February 5, 2015
- Speaker, Ralls Corporation v. Committee on Foreign Investment in the United States: Is This Landmark Ruling the Dawn of Due Process for CFIUS?, PLI Webinar, September 18, 2014
- Speaker, "Legal and Regulatory Issues that Make the Defense Sector Unique," The Defense Industry in a Time of Change, New York City Bar Association, March 27, 2014
- Speaker, "Government Security: FOCI and Other Key Issues," Annual Meeting of the Aerospace General Counsel's Group, Charleston, SC, November 4, 2010
- Speaker, "Green Labeling and Deceptive Labeling Practices," Consumer Specialty Products Association’s Consumer Product Labeling Workshop, Chicago, IL, October 16, 2008
- Speaker, "Federal Trade Commission Green Guides," Joint Committee Annual Meeting, Textile Rental Services Association, Salt Lake City, UT, August 4, 2008
- Co-author, “CFIUS Reform Flies, But With Clipped Wings,” Stroock Special Bulletin, July 26, 2018
- Co-author, “CFIUS Reform Easily Passes Senate,” Stroock Special Bulletin, June 19, 2018
- Co-author, "Under close inspection," Intellectual Property Magazine, February 28, 2018
- Co-author, "The Elephant in the Room," Stroock Special Bulletin, December 4, 2017
- Co-author, "Four Things You Need to Know About the CFIUS Reform Legislation," Stroock Special Bulletin, November 8, 2017
- Co-author, "Some Secret and Not-So-Secret Findings in the CFIUS Annual Report," Stroock Special Bulletin, September 29, 2017
- Co-author, "New Reporting Requirements For Foreign Travel and Foreign Contacts by Government Contractors," Stroock Special Bulletin, July 17, 2017
- Co-author, "Second Helpings: New Legislation Would Give Agriculture and HHS Secretaries Seats at the CFIUS Table," Stroock Special Bulletin, March 21, 2017
- Co-author, "NISPOM Amendments Affect All Cleared Contractors," Pratts Government Contracting Law Report, September 2016
- Co-author, "Food for Thought: SAFE Act Would Add the USDA to CFIUS," Stroock Special Bulletin, August 11, 2016
- Co-author, "CFIUS Reviews are a Reality for More and More Cross-Border Transactions," California International Law Journal, Summer 2016
- Co-author, "NISPOM Amendments Affect All Cleared Contractors," Stroock Special Bulletin, May 25, 2016
- Co-author, "China On Top: China Dominates CFIUS Reviews for Third Year in a Row," Stroock Special Bulletin, February 19, 2016
- Co-author, "Good News For Foreign Investors In US Defense Industry," Aerospace & Defense and Government Contracts Law360, January 27, 2016
- Co-author, "What Real Estate Cos. Need To Know About CFIUS Reviews," Law360, January 5, 2016
- Co-author, "CFIUS and The Waldorf Astoria," Stroock Special Bulletin, December 21, 2015
- Co-author, “FOCI Mitigation Update: DSS Moves to a Risk-Based Approach and the NID Process Sees Incremental Improvement,” Stroock Special Bulletin, November 23, 2015
- Co-author, “Why Compliance Matters,” Stroock Special Bulletin, November 19, 2015
- Co-author, “Will Loosening Cuban Trade Sanctions be a Boon for U.S. Business? Not Necessarily,” Stroock Special Bulletin, October 15, 2015
- "U.S. Defense Department Says Climate Change Threatens National Security – So How Green is Your Deal?" Financier Worldwide, January 2015
District of Columbia, Missouri
Harvard University, John F. Kennedy School of Government, 1982; Graduate Program for Senior Managers in Government
J.D., University of Virginia, 1975
A.B., cum laude, Dartmouth College, 1972; with High Honors in Government
Related Files & Links
In The Spotlight
July 23, 2018|China DailyChristopher Brewster quoted in “Chinese tech deals could face more US scrutiny”
June 28, 2018|The AgeChristopher Brewster quoted in “Trump softens stance towards China as trade war tension eases”
June 28, 2018|Merced Sun-StarChristopher Brewster quoted in “Trump softens trade stance toward China and raises optimism”
May 3, 2018|Press ReleaseStroock Ranked in 11 Practice Areas by Chambers USA 2018; 29 Leading Lawyers Recognized
May 1, 2018|PEREChris Brewster quoted in "Regulation: Firming up foreign direct investment"
March 15, 2018|TheStreetChris Brewster quoted in “After Losing Qualcomm, What Does Broadcom’s Hock Tan Do Now?”
February 28, 2018|The Real DealChristopher Brewster quoted in "China’s Anbang takeover could prompt national security review"
January 12, 2018|Law360Christopher Brewster quoted in "Proposed CFIUS Bill Could Have Opposite Of Intended Effect"
June 1, 2017|Press ReleaseStroock Earns Top Tier Rank in 11 Practices by Chambers USA 2017: 30 Leading Attorneys Recognized
March 24, 2017| Defense NewsChristopher R. Brewster quoted in "DoD concerned with Chinese investments in US high-tech startups"
January 17, 2017|Press ReleaseStroock Advises KUKA AG Before CFIUS Related to $5 Billion Acquisition by Chinese Investor
February 23, 2016| Defense NewsChristopher R. Brewster quoted in "Chinese Interest in US Firms Drives Case Surge for Watchdog Panel"
February 19, 2016| CNBCChristopher R. Brewster quoted in "Opaque U.S. panel hones in on China deals for third year"
July 15, 2015| Law360Christopher R. Brewster quoted in "China’s Potential Micron Deal Would Be Big Test For CFIUS"
April 10, 2015| China DailyChristopher R. Brewster and Amelia J. Schmidt quoted in "Blocking of chip exports could backfire: scientist"
March 3, 2015| Law360Christopher R. Brewster quoted in "Japanese Buyers Surprise With Sharp Uptick In CFIUS Filings"
March 2, 2015| Law360CFIUS Special Counsels quoted in "Chinese Buyers Appear Undaunted As CFIUS Toughens Up"
March 2, 2015| South China Morning PostChinese tech firms more confident in facing U.S. national security review
February 3, 2015| China DailyChristopher R. Brewster quoted in "Chinese Insurer Gets Waldorf OK"
February 3, 2015| McClatchy DCChristopher R. Brewster quoted in "U.S. clears Chinese purchase of famed NYC home to presidents, envoys, celebs"
November 26, 2014| McClatchy DCChristopher R. Brewster quoted in "Chinese firm gets big cache of U.S. government documents in unprecedented exchange over wind farm dispute"
November 12, 2014| South China Morning PostChristopher R. Brewster quoted in "Ralls gets crack at overturning U.S. order blocking its wind farms deal"
November 7, 2014| McClatchy DCJudge orders Obama to explain rejection of Chinese bid to buy Oregon wind farms on national security grounds
October 15, 2014| McClatchy DCChristopher R. Brewster quoted in "Chinese bid to buy Big Apple’s fabled Waldorf Astoria under scrutiny for national security risks"
October 1, 2014|Law360Christopher R. Brewster quoted in "New Bill Rekindles CFIUS Debate 1 Year After Smithfield"
July 28, 2014| Defense NewsChristopher R. Brewster quoted in "Court: US Must Explain Why It Rejects Foreign Deals"
July 15, 2014| Law360Christopher R. Brewster quoted in "DC Circ. Rebuke Could Shake Up CFIUS Review Process"
December 4, 2018|Stroock CommentaryNew Rules for New Deals: What you Need to Know About the CFIUS Pilot ProgramNovember 27, 2018|Stroock CommentaryCommerce Starts to Identify and Control Emerging Technologies with CFIUS ImplicationNovember 8, 2018|Stroock CommentaryWho’s Your New Neighbor?November 1, 2018|Stroock CommentaryHow Foreign-Controlled Companies Can Hold U.S. Security ClearancesOctober 31, 2018|Stroock CommentaryCFIUS meets NAICSOctober 18, 2018|Stroock CommentaryNo Safe Harbor for DeclarationsOctober 10, 2018|Stroock Special BulletinTreasury Pilot Program Requires CFIUS Declarations for All Qualifying InvestmentsOctober 5, 2018|Stroock CommentaryOut with the Old -- In with the New: DOD Replaces its 1985 Guidance on NISPSeptember 14, 2018|Stroock Commentary“Defense Authorization Bill Repeals NID Requirement”July 26, 2018|Stroock Special Bulletin“CFIUS Reform Flies, But With Clipped Wings”June 19, 2018|Stroock Special Bulletin“CFIUS Reform Easily Passes Senate”February 28, 2018|Intellectual Property Magazine"Under close inspection"December 4, 2017|Stroock Special Bulletin“The Elephant in the Room”November 8, 2017|Stroock Special Bulletin“Four Things You Need to Know About the CFIUS Reform Legislation”September 29, 2017|Stroock Special Bulletin"Some Secret and Not-So-Secret Findings in the CFIUS Annual Report"July 17, 2017|Stroock Special Bulletin"New Reporting Requirements For Foreign Travel and Foreign Contacts by Government Contractors"March 21, 2017|Stroock Special Bulletin"Second Helpings: New Legislation Would Give Agriculture and HHS Secretaries Seats at the CFIUS Table"February 13, 2017|Stroock Special Bulletin"The National Industrial Security Program Directive: Some Hits, Some Runs, Some Errors"September 2016|Pratts Government Contracting Law Report"NISPOM Amendments Affect All Cleared Contractors"August 22, 2016|Law360"Food for Thought: SAFE Act Would Add the USDA to CFIUS"August 11, 2016|Stroock Special Bulletin"Food for Thought: SAFE Act Would Add the USDA to CFIUS"Summer 2016|California International Law Journal"CFIUS Reviews are a Reality for More and More Cross-Border Transactions"May 25, 2016|Stroock Special Bulletin"NISPOM Amendments Affect All Cleared Contractors"February 19, 2016|Stroock Special BulletinChina On Top: China Dominates CFIUS Reviews for Third Year in a RowJanuary 27, 2016|Aerospace & Defense and Government Contracts Law360"Good News For Foreign Investors In US Defense Industry"January 5, 2016|Law360"What Real Estate Cos. Need To Know About CFIUS Reviews"12/21/2015|Stroock Special Bulletin"CFIUS and The Waldorf Astoria"November 23, 2015|Stroock Special Bulletin"FOCI Mitigation Update: DSS Moves to a Risk-Based Approach and the NID Process Sees Incremental Improvement"November 19, 2015|Stroock Special Bulletin"Why Compliance Matters"October 15, 2015|Stroock Special Bulletin"Will Loosening Cuban Trade Sanctions be a Boon for U.S. Business? Not Necessarily"June 24, 2015|Law360"Is Your Customer Diverting Sensitive Goods To Russia?"June 2, 2015|Stroock Special Bulletin"How Well Do You Know Your Customer? Commerce Department Says Third Parties Are Funneling Sensitive Goods to Russia"March 5, 2015|Stroock Special Bulletin"More CFIUS Cases are Going to Full Investigation"February 24, 2015|Government Contracts, Aerospace & Defense and Public Policy Law360"How DOD Is Streamlining National Interest Determinations"February 12, 2015|Stroock Special Bulletin"New DoD Policy Seeks to Streamline National Interest Determination Process"January 26, 2015|Stroock Special Bulletin"2014 Regulatory and Compliance Ups and Downs - Developments of Interest to Foreign Investors and Others in the National Security Sector"January 2015|Financier Worldwide"US Defence Department says climate change threatens national security – so, how green is your deal?"December 18, 2014|Stroock Special BulletinNew Rule Requires Reporting Foreign Investment in U.S. Businesses and Real Estate: Reporting Deadline for 2014 is January 12, 2015September 25, 2014|Law360"DeLauro Legislation Would Broaden Reach Of CFIUS Reviews"September 22, 2014|Stroock Special Bulletin"DeLauro Legislation Would Broaden Reach of CFIUS Reviews to Assess 'Net Benefit' of Foreign Investment"August 5, 2014|Stroock Special Bulletin"For Companies Operating Under Approved FOCI Mitigation Plans: A Shared Services Plan Checkup Can Avoid Unnecessary Costs"August 4, 2014|Law360"FCPA Diligence In Infrastructure Transactions"July 16, 2014|Stroock Special Bulletin"DC Circuit Reverses the Ralls Decision -- Promises a Jolt of Due Process for CFIUS Reviews"June 30, 2014|Stroock Special Bulletin"When is a Corporate Officer a 'Foreign Official'? Under the FCPA, a Foreign Corporation Can Still Be a Government Instrumentality. Does the Distinction Matter?"June 26, 2014|Stroock Special Bulletin"FCPA Diligence in Infrastructure Transactions"April 23, 2014|Stroock Special Bulletin"Defense Department Publishes Interim Final Rule Detailing Its Process for Clearing Contractors under Foreign Ownership, Control, or Influence"April 3, 2014|Bankruptcy, Aerospace & Defense and Government Contracts Law360"Bankruptcy Issues The Defense Industry Should Think About"January 9, 2014|Stroock Special Bulletin"CFIUS Annual Report Highlights Chinese Investment and Signals Tougher Reviews"November 18, 2013, Issue 1Stroock POSITIVE ENERGYOctober 21, 2013|Stroock Special Bulletin